Dr Christiana HJI Panayi, BA BCL PhD

Professor in Tax Law

Profile

Christiana is a Professor in Tax Law at Queen Mary University of London. She teaches on the EU Tax Law, International Tax Law and Transfer Pricing courses of the LLM Programme. She is also an Adjunct Professor of European Union Tax Law at New York University and a Visiting Professor at Sorbonne University (Ecole de droit de la Sorbonne, Université Paris 1). Christiana was also a Visiting Professor at Sorbonne University in 2012-2013 and a Visiting Professor at the University of Lausanne in 2014-2015.

In March 2015, Christiana was appointed to the European Commission’s Joint Transfer Pricing Forum (JTPF) as an expert. The JTPF is a very prestigious body which assists and advises the European Commission on transfer pricing tax matters. In May 2016, Christiana was also appointed to the European Commission’s Platform for Tax Good Governance, as an expert. In addition, Christiana is a researcher at the Institute for Fiscal Studies and has received two grants to conduct research for the Singapore Management University.

Christiana speaks regularly at tax conferences and teaches abroad. She has lectured at New York University, the University of Cambridge, Boston College, the University of Lausanne, the Chartered Institute of Taxation, the European Commission, the Academy of European Law, the Vienna University of Economics and Business Administration, the University of Lisbon, the University of Amsterdam and various other universities. She has also designed and conducted workshops on International and EU tax law for Her Majesty’s Revenue and Customs, the UK Treasury and various south European organizations and accounting firms.

Christiana studied at Oxford University for her BA in Jurisprudence and for the BCL. She also has a PhD from the London School of Economics. She is a solicitor of England and Wales and an advocate of the Cyprus Supreme Court. Before joining Queen Mary, Christiana worked for Allen and Overy LLP. Christiana is also a member of the Law Society of England and Wales, and the Cyprus Bar Association.

She is also a member of the BEPS Monitoring Group, a member of the OECD’s International Network of Tax Research, a member of the European Association of Tax Law Professors and a member of the Examination Sub-Committee of the ADIT (Advanced Diploma in International Taxation). In the past, she was external examiner at the University of Dundee and the University College Dublin.

Postgraduate Teaching

Research

Research Interests:

Christiana’s research interests are in the area of European Union tax law, international tax law, tax policy and corporate governance. She also has an interest in international treaty law and EU state aid law. Christiana is one of the leading researchers on the Common Consolidate Corporate Tax Base.

Her latest research is encapsulated in her monograph entitled Advanced Issues in International and European Tax Law. In this monograph, topics such as international tax avoidance, corporate social responsibility, good tax governance, harmful tax competition, state aid, tax treaty abuse and the Financial Transaction Tax are considered. The OECD/G20 project on Base Erosion and Profit Shifting (BEPS) features prominently and its interaction with the European Union’s Action Plan to strengthen the fight against tax fraud and tax evasion is considered.

Research Projects

In 2015, the Singapore Management University - Tax Academy Centre for Excellence in Taxation (SMU – TA CET) gave Christiana a grant to do research on Exchange of Information, the New Common Reporting Standard and the Singapore/Asian perspective. The SMU-TA CET is a tax research centre set up by the Tax Academy in collaboration with the Singapore Management University and with the strong support of IRAS. It is the first centre in Singapore that is dedicated to research on international taxation with particular focus on Asian economies and tax systems.Following the completion of the project, her paper entitled Current Trends on Automatic Exchange of Information was published in the special tax issue of the SMU School of Accountancy Working Paper Series, in January 2016. Since then, Christiana has received an additional grant to conduct research on international tax law in the post-BEPS world. The paper for this research was posted on SSRN and an updated version of it was published by the IBFD’s Bulletin for International Taxation.

Furthermore, Christiana participated in the European Commission’s Study on Aggressive Tax Planning which was released in the context of the hugely influential Anti-Tax Avoidance Package.

Publications

Books

“This book […] is both comprehensive and insightful. As Philip Baker QC comments in the Foreword, “many of the issues covered in this book are ones that the European Community is just beginning to consider” (p.xii). [...] In the meantime, Christiana Panayi's book offers the reader the opportunity to reflect on some of the obstacles before us, as well as on possible outcomes. As the author rightly observes, “these are certainly interesting times, even in tax law””. See [2008] 1 British Tax Review 96-98.

Winner of tax thesis award of European Commission and European Association of Tax Law Professors (2007)

“It is a comprehensive analysis of EU corporate tax law, demonstrating great knowledge and insight. It represents a great addition to existing literature and—this reviewer has no doubt—will soon become a reference in this area”. See [2013] 5 BTR pp. 691-694.

“An excellent and complete overview of EU taxation: Christiana provides a simple and enjoyable overview of very complex issues and legal doctrines”. Pierpaolo Rossi of European Commission Legal Services

“Professor HJI Panayi’s unique and most valuable book has the potential of becoming the turning point in this increasingly complex field”. See [2016] 44 Intertax pp.284-287.

“A book like this is a well-designed guide for those coming to the area for the first time, as well as a record for the future […]. It is a welcome addition to the literature in the fields of both international taxation and EU direct taxation.” (Book Foreword by Philip Baker QC).

“Harmonization and Direct Taxes – Is it Really Needed?” in Studies in European Public Law: Thematic, National and Post-National Perspectives (Sakoulas Publications, 2010); ISBN: 978-960-445-530-0

“Rethinking treaty-shopping: Lessons for the European Union”, in Tax Treaties: Building Bridges between Law and Economics (IBFD Publications, 2010), pp.18-50; ISBN: 978-90-8722-085-3 (jointly with Reuven Avi-Yonah)

Public speaking engagements

2016

Organised seminars on EU Tax Law at the Malta Institute of Management (October 2016)

Participated as an expert at the meeting of the Platform for Tax Good Governance (September 2016)

Participated as an expert at the meeting of the Platform for Tax Good Governance (June 2016)

Speaker at conference of University of Amsterdam. Title of conference: “Anti-BEPS Implementation in the EU”. Title of paper: “The CFC provision of the proposed Anti-Tax Avoidance Directive” (June 2016)

Speaker at Cambridge University’s Tax Policy Conference (April 2016)

Guest speaker at the London School of Economics tax seminars (March 2016)

Participated at the OECD meetings of the steering group of the International Network of Tax Research (February-March 2016)

Participated as an expert at the meeting of the Joint Transfer Pricing Forum (February 2016).

2015

Speaker at the Athens Tax Forum, organised by the American Hellenic Chamber of Commerce (April 2015)

Lectured LLM students at the University of Lausanne, on the topic of mergers and reorganisations (April 2015)

Lectured at NYU, at the international tax programme (March 2015)

Plenary speaker at the Annual International Tax Conference of the Malta Institute of Management. Title of conference: “Taxpayers’ rights in a changing international landscape”. Title of paper: “Tackling Tax Avoidance in the European Union”.

2014

Speaker at conference organised by the American-Hellenic Chamber of Commerce in March 2014. Title of conference: “10th Athens Tax Forum”. Title of paper: “Tax Avoidance Internationally and in the European Union”

Organised seminars on EU Tax Law at the Malta Institute of Management.

2013

Speaker at conference organised by the London School of Economics in November 2013. Title of conference: “Resolving Tax Treaty Disputes: A Global Analysis”. Plenary speaker. Also contribution of paper entitled: “Resolving Tax Treaty Disputes in Former Tax Havens”

2012

Organised and conducted training seminars for top ranking employees at HM Treasury and HMRC on the topic of the Common Consolidated Corporate Tax Base in October 2012. Speaker at conference organised by the University of Lisbon in June 2012. Title of conference: “EU Tax Policy Conference”. Title of paper: “The CCCTB: Selected Issues”

Taught a one-day workshop at the Cambridge Centre for Tax Law in May 2012. Gave paper on the CCCTB and Anti-Abuse rules

Speaker at conference organised by the Institute for Austrian and International Tax Law of the Vienna University of Economics and Business Administration in January 2012. Title of conference: “CCCTB and Third Countries”. Title of paper: “The CFC rules within the CCCTB”.

2011

Organised the KPMG International Tax Law Conference in Cyprus in April 2011, with speakers from the European Commission, leading UK tax barristers and others

Organised seminars on EU Tax Law at the Malta Institute of Management.

2010

Speaker at conference organised by the Institute for Austrian and International Tax Law of the Vienna University of Economics and Business Administration in March 2010. Title of conference: “Tax Treaties Issues from a Legal and Economic Perspective”. Title of paper: “Rethinking treaty-shopping: Lessons for the European Union”.

Speaker at the Chartered Institute of Taxation seminars in January 2010. Title of paper: “Marks & Spencer and UK Group Relief Rules: A never ending saga?”.

2009

Organised the KPMG International Tax Law Conference in Cyprus in October 2009, with speakers from the European Commission, leading UK tax barristers and others

Organised seminars on EU Tax Law at the Malta Institute of Management.

2008

Conference organised by the University of Cyprus in October 2008. Title of conference: “Harmonisation in Practice: The Paradigm of European Public Law”. Title of paper: “Harmonisation and Direct Taxes: Is it really needed?”

Conference organised by the Institute for Austrian and International Tax Law of the Vienna University of Economics and Business Administration, in cooperation with the Taxation and Customs Union DG of the European Commission, in February 2008. Title of conference: “Common Corporate Consolidated Tax Base: The Possible Content of Community Provisions.” Title of paper: “Thin Capitalisation and Inbound Investment”.

2007

Speaker at conference organised by the Academy of European law (ERA Congress), in Trier, Germany in October 2007. Title of conference: “Does competition law still allow for tax planning by European firms? How to reconcile taxation and state aids.” Title of paper: “UK System: Tax Benefits for UK offshores”.

2006

Speaker at Fiscalis Seminar entitled “Tax Treaties and EC Law”, organised by the European Commission in October 2006. Title of paper: “Effects of the Accession Treaty on pre-existing tax treaties: legal aspects”. Subsequently published in EC Tax Review (2007) vol.3.